Protect orcas from the shipping industry

Reference Number

To the Honorable Impact Assessment Agency of Canada:


I urge the federal government of Canada to reject the proposed Roberts Bank Terminal 2 project.


The Federal Review Panel Report for the Roberts Bank Terminal 2 Project was clear in its findings that this project will have devastating impacts on critical wildlife habitat and the Salish Sea ecosystem:


“The Panel concludes that the Project would result in numerous adverse residual and cumulative effects. The proposed offsetting plan for aquatic species, totaling 29 hectares, would be insufficient to compensate for the reduction in productivity associated with a Project-induced habitat loss of 177 hectares of Roberts Bank.”


“There would be significant adverse and cumulative effects on Dungeness crab as well as ocean-type juvenile Chinook salmon originating from the Lower Fraser and South Thompson Rivers.”


“The Project would cause significant adverse and cumulative effects on SRKW [Southern Resident killer whales] … a lethal vessel strike on a single individual SRKW could have significant adverse population consequences.”


“If a worst-case oil spill were to occur in the marine shipping area, it could result in potentially significant adverse residual effects for vulnerable species such as SRKW and marine birds, marine commercial and recreational activities, current use, cultural heritage, and health of Indigenous groups.”


As the joint review panel found in its final report on the project, Roberts Bank T2 would have significant adverse effects on Chinook by disrupting their migration and impacting underwater light and acoustics. The panel also found the project would have significant adverse and cumulative effects on the Southern Residents through habitat loss, an increase in underwater noise, and reduced availability of Chinook salmon, which are the whales’ main source of prey.


In addition, the Fraser River Estuary has global significance and serves as a crucial stopover on migration routes stretching between South America and the high Arctic. Environment Canada concluded that the impacts from this project would increase the threats to shorebirds generally and western sandpipers specifically, and that these risks cannot be mitigated.


There is no evidence that demonstrates that any of the above damage can be offset with mitigation strategies. Habitat mitigation and habitat offsetting are not effective in addressing the negative effects from terminal projects (Lievesley et al. (2016) found that only 33% of the Port of Vancouver’s own habitat offsetting projects obtained their intended goals, and the Canada-wide study by Quigley and Harper (2006) determined that 50% of fish habitat mitigation projects were not compensating for damages on a 1:1 ratio).


The loss of critical habitat in the Fraser River Estuary and the additional 520 container ship transits per year from Roberts Bank Terminal 2 will only serve to further accelerate the current climate and biodiversity crises. If the recovery and conservation of Canada’s endangered and iconic wildlife species are a priority for the Government of Canada, then this project must be rejected. 


If the federal government of Canada approves the proposed Roberts Bank Terminal 2 project, the conditions need to include requirements for emergency response vessels with firefighting capabilities and Emergency Towing Vessels to be on stand-by year-round.


The 2021 fire aboard the Zim Kingston was contained by two tugs with firefighting capabilities that just happened to be at a nearby dock. A large-scale environmental disaster was averted. The Zim Kingston is a 4,253 TEU container ship. As proposed, 24,000 TEU container ships would call on Roberts Bank Terminal 2. Emergency response vessels with firefighting capabilities for 24,000 TEU containerships are an essential condition.


Container ships carry large volumes of propulsion fuel that could cause a catastrophic oil spill if an accident occurs. In order to prevent accidents and oil spills, Emergency Towing Vessels capable of effectively responding to 24,000 TEU container ships in distress are needed along the project’s vessel traffic route through the Salish Sea.


Please reject the proposed Roberts Bank Terminal 2 and demonstrate a commitment to Canada’s Species at Risk Act and Canada’s Wild Salmon Policy and to the integrity of the Salish Sea’s biodiversity and ecosystems.


Thank you for considering my comments.



Kind Regards,

Caleb Merendino

Submitted by
Administrator on behalf of Caleb Merendino
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